In this startling document submitted to the Massachusetts Department of Public Utilities, Northeast Utilities in Massachusetts lays out its objections to the Smart Meter program, including that Smart Meters are not needed to achieve grid modernization or achieve energy savings.

It states: “There is no rational basis for the implementation of AMI.”

AMI (Advanced Metering Infrastructure) meters are Smart Meters.

The document states that

Meters do not reduce the number of outages;

Metering systems are not the only option for

optimizing demand

reducing system costs, or

reducing customer costs;

Metering systems are not necessary

to integrate distributed resources,

to improve workforce management, or

to improve asset management.

It discusses the rising cost to consumers.

In this document, it is very troubling to read that there was a 6 month technical review by DPU but that it was conducted “off the record”.

Letter and formal comments

From: NSTAR Electric Company and Western Massachusetts Electric Company (collectively known as Northeast Utilities)

To: Massachusetts Department of Public Utilities (DPU)

There Is No Rational Basis for Department-Mandated Implementation of AMI

An Advance Metering System is not a “basic technology platform” for grid modernization and is not needed to realize “all of the benefits of grid modernization.”

…[T]there is no evidence that this is a good choice for customers.

The Department identified four objectives for grid modernization, all of which can be achieved without the implementation of an advanced metering system.

Therefore, it is not correct that advanced metering functionality is a “basic technology platform” that must be in place before all of the benefits of grid modernization can be fully realized, as the Department suggests. Id. at 12.

Finite capital resources available for grid modernization should be aimed at this integration effort before any additional monies are expended on metering capabilities that provide limited and/or speculative incremental benefits over current metering technology (following many years of investment in those systems).5

Moreover, the growth of distributed generation and current subsidies results in the bypass of the electric distribution system by potential electric customers leaving fewer and fewer customers to pay for it. This creates a pricing crisis in practical terms for both residential and business customers remaining on the system. Huge additional investments to the distribution system will only have the effect of exacerbating the issue for customers.

The decision to implement AMI goes against the best business judgment of the Companies and cannot be rationally cost justified in terms of a net benefit for the overall customer base that will pay for the investment over the long term.

The mandated implementation of AMI is not a prerogative within the Department’s discretion. The specification of particular technologies or technological platforms is an issue within the management judgment of the Companies and which would only be undertaken on the basis of all relevant investigation and analysis.